In this Privacy Statement, we have provided information about data collected and used when you purchase a Volkswagen vehicle or otherwise interact with Volkswagen and its websites, mobile applications, vehicles, products and services, and data collected and used when you receive Car-Net® Services (defined below).
If you are the vehicle owner, you must notify any additional drivers about the privacy practices described in this Statement and if you are the Primary Driver for this vehicle’s Car-Net Services, you must notify any additional drivers of the vehicle about the Car-Net specific privacy practices described herein.
Last Modified: July 10, 2020
At Volkswagen of America, an operating division of Volkswagen Group of America, Inc., (“VW,” “we,” or “us”), we value your privacy and want you to know how your information will be handled and used. This Privacy Statement applies to information we obtain from and about individuals interacting with VW and its websites, mobile applications, vehicles, products and services; however, it does not apply to job applicants or VW employees.
Your vehicle contains hardware and software that enables you to receive the personal assistance and telematics-based services provided through VW Car-Net (the “Car-Net Services”).
This Statement does not apply to VW Credit, Inc. (“VCI”) or its products, contracts and related services. VCI has its own privacy statement, which can be found here.
Below we provide a summary of the general information we collect, how we use it and with whom it is shared.
If you are a California resident, please view the “Your California Privacy Rights” section of the full privacy statement for more information on your California privacy rights.
Table of Contents
1. From What Sources Do We Collect Information?
As you interact with VW and its websites, mobile applications, vehicles, products and services, we may collect certain information from or about you or your vehicle from the following sources:
- Directly from you. We collect the information you provide to us directly or when you interact with us, such as when you visit or use our website, use VW and third-party digital properties (including social media sites and sweepstakes microsites), use VW mobile applications, or during other interactions such as product and related events, test drives, surveys, promotion entries, and when you interact with our customer call centers.
- Cookies and online technologies. When you access or use our website, VW and third-party digital properties (including social media sites and sweepstakes microsites), or VW mobile applications, we may collect data through cookies and other tracking technologies.
- Authorized VW Dealers. We receive information through leasing, service and other records provided to us by Authorized VW Dealers.
- VW-authorized sellers of consumer merchandise.
- VCI (if you finance your VW vehicle purchase or purchase products from VCI) and other companies within the Volkswagen Group family of companies.
- Third party service providers, Integrated Content Providers and Optional Third Parties (defined below).
- Other third parties, such as companies that provide or sell lists of potential vehicle purchasers and current owners (data brokers), business partners, social media platforms and networks.
2. What Information Do We Collect?
As you interact with VW, its products and services, we collect different types of information from you, based on the interaction, such as when you purchase a vehicle and subscribe to Car-Net Services. The types of information that VW collects about you include:
- Identifiers, characteristics and other information you provide, including contact information; authentication information you create (such as a Volkswagen ID); your preferences, photographs and other user-generated content; other materials that you may submit; demographic information; account information, including billing (as well as financial data used for payment purposes); settings; personalized services and authentication information.
- Commercial information regarding vehicle purchase/lease/service, including contact information (such as name, address, telephone number, email) and vehicle purchase, lease or service information (such as VIN, make, model, year, dealer, date of purchase or lease, purchase/lease price, vehicle equipment, and service history) as well as other purchasing or consuming histories or tendencies.
- Commercial and electronic activity information, such as vehicle data transmitted from your vehicle, or collected or inferred from your use of the vehicle services, including general status data (such as warning lights, upcoming service schedule, fuel level, battery level, and tire pressure); service history and fault or trouble codes; ambient data (such as outside temperature and brightness); vehicle performance data and other data about your vehicle including its identification, condition, equipment status, or collision information; vehicle/technology usage data (such as usage of lock/unlock and remote start technology); driver behavior data (such as vehicle speed, seat belt use, and information about braking habits); information that you provide when using Car-Net Services, including information you send and information you request; and information about your interactions with us, our affiliates, our service providers or Integrated Content Providers or Optional Third Parties (defined below).
- Electronic activity, such as data gathered by technology when you visit our website or use our mobile applications (such as IP address, browser information, ICCID, device type, app and OS version, etc.) as well as information about your use of Car-Net Services, the Car-Net mobile application, and the Car-Net website.
- Geolocation data.
- Audio, electronic, visual, thermal, olfactory, or similar information, such as call recording for emergency and customer service and voice command data (including any personal data included therein).
- Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences and characteristics, demographics and vehicle usage patterns.
3. How Do We Use Your Information?
We collect and use your information for a number of business purposes, such as:
- To provide you with products and services, such as to provide products and services you request; support your vehicle, products and services; diagnose, repair and track service and quality issues; communicate with you about your vehicle, products or services; install and configure changes and updates to your services; authenticate users of our products and services; verify your eligibility for certain programs or benefits; or to provide you with Car-Net Services.
- For our own internal business purposes, such as to evaluate the usage, performance and safety of our vehicles, products and services; improve the quality of our vehicles, products and services and design new products and services; operate the VW website and digital properties and customize the content; and maintain internal records.
- For legal, safety or security reasons, such as to comply with legal requirements; protect the safety, property or rights of VW and the Volkswagen Group family of companies, including VCI (and its right to repossess its vehicles, including through the use of GPS data); owners, registered users, drivers, passengers or others; or prevent and detect fraud or misuse of the vehicles, products or services.
- For marketing, however, please note that precise GPS location data or your driver behavior data will not be used for VW marketing purposes or shared with unaffiliated third parties to use for their own marketing purposes without your affirmative consent.
- In a de-identified or aggregated format, we may also use or share your information in a de-identified or aggregate manner for any purpose.
- For services of third parties that you authorize, with your consent, we will provide the information needed by third parties that we introduce or with whom you independently engage in order to provide their services to you.
5. Your choices
To opt-out of receiving promotional email messages from us, please click on the "Unsubscribe" link contained at the bottom of each email. Opting out of promotional email will not affect VW’s communication with you by email about your vehicle or other product or service-related matters.
You can discontinue the Car-Net Services data collection described in this Privacy Statement at any time by unenrolling your vehicle from Car-Net. However, this will result in loss of Car-Net Services. For Model Year 2020 and newer vehicles, you can unenroll from Car-Net via the Car-Net website, Car-Net mobile app or by calling Car-Net Response Center at 1-833-648-2735. For Model Year 2019 and older vehicles, you can unenroll by calling 1-877-820-2290.
Please note that the information stored in your VW vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your VW vehicle or mobile device, and thus may be deleted, altered, or transferred.
Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.
Please contact us at firstname.lastname@example.org to inquire about your right to opt out of the sale of your personal information.
Please see the Your California Rights section for more information about your privacy choices.
6. Online Advertising
9. Our Commitment to Children's Privacy
VW does not knowingly collect, use, share or sell the information of children under the age of 16. In the event that we learn that we have collected information from a child under age 16, we will delete that information. For questions or additional information, see the “Contact Us” section below.
VW maintains reasonable safeguards to protect your information. Some services, including Car-Net® Services, may involve the transmission of voice and data from your VW vehicle over wireless and cellular telephone networks and therefore, we cannot guarantee the privacy and security of conversations or data transmitted to and from your VW vehicle.
12. Changes to this Privacy Statement
From time to time, we may update this Privacy Statement by updating this page and by displaying the date of the last update at the top of the page. We encourage you periodically to check this site to learn about the information we collect, use, and share. Your continued use of any of the VW websites, products or services affirms your agreement to such changes.
Should you have other questions or concerns about this Privacy Statement,
You may contact us 24 hours a day, at: 1-800-822-8987.
Office of General Counsel
Volkswagen Group of America
Attn: Privacy Office
2200 Woodland Pointe Avenue Herndon, VA 20171
If you are eligible for and opt-in to DriveView (a usage-based insurance program), VW will collect and use commercial and electronic network activity information collected through Car-Net Services about your driving behavior, such as speed, braking and seat belt usage, and GPS location in order to assess your driving and routinely provide you a DriveView score (i.e. a score based on certain factors that are considered higher indicators of risk collision, such as hard braking, nighttime driving, idle time and high speed). We will collect this data directly from you and your use of the Car-Net technologies. We also will use aggregated data to conduct driver behavior modeling (for example, comparing drivers across different states). If you opt-in and direct us to do so, we also will send your driver behavior and GPS location data to our insurance company partners for consideration. They may offer discounts depending on your driving record. You can also opt-in to DriveView and direct us to share your driving data and GPS location data with your existing insurance carrier. We will provide it only at your direction, but you may discontinue sharing at any time by un-enrolling in DriveView.
Please visit the Car-Net website for more information about the DriveView program, eligibility requirements and how you can participate.
15. Your California Privacy Rights
In addition to the information provided above about the data we collect and how we use and share it, in accordance with the California Consumer Privacy Act (CCPA), below is a list of the categories of personal information collected and for each category, the categories of third parties with whom we share the personal information for a business or commercial purpose.
Category of Personal Information
Categories of third parties to whom it was disclosed for a business purpose
Categories of third parties to whom it was sold for marketing purposes
Identifiers, characteristics and other information you provide (2.1)
Commercial information regarding vehicle purchase/lease/service (2.2)
Commercial and electronic activity information, such as vehicle data transmitted from your vehicle (2.3)
Electronic activity (2.4)
Geolocation data (2.5)
Audio, electronic, visual, thermal, olfactory, or similar information (2.6)
Categories of third parties to whom it was disclosed for a business purpose
- Within the Volkswagen Group family of companies (4.1)
- With third-party service providers (4.2)
- With VW Dealers (4.3)
- With others for legal, security or safety purposes (4.4)
- With other companies in connection with a VW corporate transaction (4.5)
- Integrated Content Providers (4.7) Optional Third Parties (4.8)
Categories of third parties to whom it was sold for marketing purposes
- With third parties for their own marketing purposes, such as Sirius XM, VW Dealers, Verizon and select companies with whom we may partner to offer you products or services. (4.6)
As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information.
You can submit a Data Subject Rights Request by clicking (http://privacy.vwgoa.com/), and following the instructions in the web form, or you can call (833) 909-1767.
Please note that certain rights may be limited where your personal information is subject to certain state or federal laws, such as the Fair Credit Reporting Act (“FCRA), the federal Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act.
- Right to Opt-Out/Do Not Sell
California Consumers have the right to request that we not sell your personal information to third parties. However, even if you opt-out, we are allowed to continue sharing with service providers as permitted by law.
- Right to Delete
California Consumers have the right to request that we delete personal information about you that we have collected from you.
- Right to Know
California Consumers have the right to request that we disclose personal information that we have about you. You can request that we provide you with the categories of personal information we have collected in the 12 months preceding your request, and information about how we used and shared those categories of information. You can also request that we provide you the specific pieces of personal information that we have about you.
California Consumers can submit a Request to Know twice in a 12-month period and the report will be provided free of charge.
In order to verify your identity, match you to our records, and to reduce fraud, will ask you for your personal information or information about you. You will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also ask you to provide a signed declaration, under penalty of perjury, that you are the person whose personal information is the subject of the request. We also use third party verification companies to help us verify your identify.
- Household reques
If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above.
- Use of authorized agent
If you are making any of the requests above as an authorized agent, we will require written authorization or a valid Power of Attorney. Additionally, we will seek to verify your identify in the manner stated above. To make a request using an authorized agent please call (844) 987-2272.
- Timing of Response
We will respond to Requests to Delete and Requests to Know within 45 calendar days, unless we need more time, in which case, we will notify you. It may take up to 90 calendar days in total to respond to your request. We will respond to Requests to Opt-Out/Do Not Sell within 15 business days.